NRC-FirstEnergy meeting on 12/17/15 re: concerns with Davis-Besse's emergency diesel generators

On Mon., Dec. 14th, NRC staff publicly announced that a meeting originally scheduled for Tuesday morning, Dec. 15th, has been rescheduled for Thursday morning, Dec. 17th, beginning at 10:30am Eastern. The meeting will take place by teleconference, re: a License Amendment Request (LAR) by FirstEnergy, to revise  required safety standards regarding Emergency Diesel Generators (EDGs) at Davis-Besse.

Here are the toll-free call-in numbers:

Phone: 888-950-6757

Passcode: 12158

Concerned local residents, environmental group representatives, and news media reporters are encouraged to call-in. 

The postponement of the meeting was announced just a few hours after the filing of an official allegation concerning Davis-Besse's EDGs by David Lochbaum, director of the Nuclear Safety Program at Union of Concerned Scientists. 

Lochbaum has documented that concerns with the EDGs at Davis-Besse date back not months, but years -- to 2012. (See "Additional Relevant Documents" linked at the bottom of this web post.)

The application was submitted 4/1/15 and is available under ADAMS Accession No. ML15091A143. (Beyond Nuclear received this doc as a PDF from Blake Purnell, and posted it at the Beyond Nuclear website at the following link: http://static1.1.sqspcdn.com/static/f/356082/26729948/1449862061550/4+1+15+ML15091A143+-+Davis-Besse+-+License+Amendment+Request+to+Revise+Emergenc....pdf?token=IBYEWgfqTzERpW5%2BZirIXFajX2U%3D )

By letter dated Sept. 21, 2015 (ML15222A179), the NRC requested additional information to complete its review of the License Amendment Request (LAR). FENOC response, dated 10/14/15, is immediately below.

A supplement to the application was submitted on 10/14/15 and is available under ADAMS Accession No. ML15287A251. (It is viewable online at the NRC's website, posted here: http://pbadupws.nrc.gov/docs/ML1528/ML15287A251.pdf )]

On Dec. 7, 2015, NRC's Mr. Purnell emailed more detailed "Questions for Meeting" to Beyond Nuclear's Kevin Kamps. (Please note, as mentioned above, the meeting will now take place on Thursday, December 17th at 10:30am Eastern.)

However, Lochbaum's allegation email cited above documents that concerns regarding Davis-Besse's EDGs date back not to April 2015, but rather to 2012. (See "Additional Relevant Documents," listed at the bottom of this web post.)

Shockingly, and frighteningly, it appears that 45 years after NRC's predecessor agency, the U.S. Atomic Energy Commission (AEC) established basic EDG safety standards, and nearly 40 years after Davis-Besse began operating, they still don't have assurance that the EDGs will work correctly, or at all, if called upon!

Here is NRC's basic agenda for the meeting, including NRC points of contact:

[Title: Meeting with FirstEnergy Nuclear Operating Company

Date(s) and Time(s): December 17, 2015, 10:30 AM to 11:00 AM

Location: Teleconference

Category: This is a Category 1 meeting. The public is invited to observe this meeting and will have one or more opportunities to communicate with the NRC after the business portion of the meeting but before the meeting is adjourned.

Purpose: Discuss April 1, 2015, license amendment request to revise emergency diesel generator minimum voltage and frequency surveillance requirements at Davis-Besse Nuclear Power Station.

Contact: Blake Purnell, 301-415-1380

Blake.Purnell@nrc.gov

[Blake Purnell, Project Manager, Plant Licensing Branch III-2 and Planning and Analysis Branch, Division of Operating Reactor Licensing, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission]

and

Jennifer Hauser, 301-415-1687

Jennifer.Hauser@nrc.gov ]

ADDITIONAL BACKGROUND INFORMATION ON SAFETY SIGNIFICANCE OF EDGs

As so tragically shown at Fukushima Daiichi, the emergency diesel generators (EDGs) are the last line of defense against reactor core meltdown and catastrophic radioactivity release.

In June 1998, after a tornado scored a direct hit at Davis-Besse, passing between the Shield Building and cooling tower, destroying the electric grid (and thus the primary source of electricity to run safety and cooling systems), the emergency diesels nearly failed. The second and last EDG broke down a number of times over the course of the ensuing day after the tornado struck. The headline in the Kalamazoo Gazette, a day or two after the smoke cleared, was "Nuclear Disaster Averted" at Davis-Besse. "Narrowly" went without saying.

Dave Lochbaum at UCS said at the time that but for the extraordinary efforts by Davis-Besse personnel, such as to revive the repeatedly failing second and last EDG, that nuclear disaster may not have been narrowly averted.

As Fukushima has shown, hot reactor cores have to be cooled for days after the nuclear reaction is stopped, or else they'll still melt down due to the decay heat. Dr. Gordon Edwards of Canadian Coalition for Nuclear Responsibility recently made this point at the Port Huron, MI day-long event opposing the Canadian Great Lakes shore nuke waste dump on Nov. 9th. He pointed out that the radioactive decay, alone, still generates around 10% of the thermal heat of an operating reactor core, more than enough to melt down the core without active cooling. That's how very radioactive (as well as thermally hot) irradiated nuclear fuel is. It's why, nearly five years after the meltdowns at Fukushima, Tokyo Electric still pumps hundreds of tons of cooling water per day into the ruined reactors (even though they don't know exactly WHERE the melted cores are located!), to prevent another overheating, re-meltdown, and renewed "China syndrome." It's also why irradiated nuclear fuel must be cooled for at least five years in high-level radioactive waste storage pools, before transfer to air-cooled dry cask storage (it's too thermally hot, not to mention too radioactive, before that, for storage in dry casks).

By the skin of its teeth, Davis-Besse avoided a core meltdown in June 1998. My understanding is the second and last EDG gave up the ghost for good, shortly after the grid was restored, to provide electricity to the safety and cooling systems. I assume that while Davis-Besse workers were performing repeated "CPR" on the second, and last, EDG, other FirstEnergy work crews were racing to restore the grid in time.

It's incredible that our society is willing to play such high-stakes games of "radioactive Russian roulette," when electricity could be provided safely with renewables and efficiency (not to mention securely, cleanly, affordably, reliably, etc.). In fact, Dr. Al Compaan, emeritus professor of physics at UT, served as our environmental coalition's expert witness in our intervention against the 20-year license extension at Davis-Besse, testifying that solar photovoltaics (PV) alone, or wind power alone, could readily replace Davis-Besse's 908 Megawatts-electric. (Of course, solar PV and wind power in combination could all the more readily replace Davis-Besse!) The NRC Atomic Safety and Licensing Board Panel was interested to hear more, and granted us a hearing on the technical merits of our renewable alternatives to 20 more years of Davis-Besse's risks. But FirstEnergy appealed that ruling. The NRC Commissioners sided with FirstEnergy, and overruled the licensing board. Thus, our hearing denied.

Just below is pasted in the section, re: the June 1998 tornado strike "near miss," from Beyond Nuclear's 2010 backgrounder on Davis-Besse's many close calls with catastrophe [the full backgrounder is posted online at: http://static1.1.sqspcdn.com/static/f/356082/9994732/1293650246863/Davis+Besse+20+More+Years+of+Radioactive+Russian+Roulette+Nov+2010+corrected+Dec+28+2010.pdf?token=ttX228310Ed3CI9ZXWzCw%2FYRzFk%3D]

Direct hit by tornado, June 24, 1998

An F2 tornado, with wind speeds of 113 to 157 miles per hour, scored a direct hit on Davis-Besse, with the funnel cloud passing between the cooling tower and the containment building. The control room operators, running the reactor at 99% power, had little to no advance warning of the twister, until alerted by the guard shack, which had spotted it approaching the plant. Although the reactor was then immediately scrammed, a large amount of radioactive decay heat in the core would need to be actively cooled for many hours, even days. As a safety precaution, operators immediately attempted to initiate the plant’s two emergency diesel generators (EDGs). However, the first EDG initially failed to start, and was forced more than once over the course of the next day to be declared inoperable due to overheating of the room housing it. In addition, the second EDG was later declared inoperable “due to an apparent problem with the governor control.” This “uncertainty of the operability of the EDGs” was a very serious concern, as the tornado had caused extensive damage to Davis-Besse’s electrical switchyard, as well as to the region’s electrical transmission lines, leading to a complete loss of offsite power that lasted for nearly 27 hours. Thus, the EDGs were needed to cool the thermally hot core, as well as to cool the irradiated nuclear fuel storage pool, for over a day. Complete failure of both the offsite power supply, as well as the EDGs, could lead to core damage and even a meltdown in a short period of time, as well as boil off of the radioactive waste storage pool’s cooling water supply [after many days], which could cause spontaneous combustion of the irradiated nuclear fuel within [a short period of time after irradiated nuclear fuel rods were exposed to air]. Such a reactor meltdown and/or pool fire could result in catastrophic radioactivity releases.24 In addition to the dicey electricity supply to run vital safety and cooling systems, Davis-Besse’s emergency alert system and communications were largely destroyed or inoperable. For example, most of the emergency sirens across Ottawa County no longer worked after the electrical distribution system was so severely damaged. Ironically, when needed most, the emergency sirens did not work. Thus, the public would have been “in the dark” had there been radiological releases, and Davis-Besse could not even communicate with the State of Ohio or neighboring counties to coordinate emergency response.25

Footnote 24: See, for example, Technical Study of Spent Fuel Pool Accident Risk at Decommissioning Nuclear Power Plants (NRC, NUREG-1738, 2001), as well as the 1982 NRC/Sandia National Lab report, “Calculation of Reactor Accident Consequences” (CRAC-2).

Footnote 25: See: NRC news releases, both dated June 25, 1998, “NRC TEAM DISPATCHED TO DAVIS-BESSE NUCLEAR PLANT,” (http://permanent.access.gpo.gov/lps11598/www.nrc.gov/reading-rm/doc-collections/news/1998/98-40iii.html), and “NRC INSPECTION TEAM MONITORING DAVIS-BESSE PLANT  RESPONSE TO TORNADO DAMAGE AND LOSS OF OFFSITE POWER,” (http://permanent.access.gpo.gov/lps11598/www.nrc.gov/reading-rm/doc-collections/news/1998/98-40aiii.html); see also LICENSEE EVENT REPORT (LER) 1998-006-00, “Tornado Damage to Switchyard Causing Loss of Offsite Power,” EVENT DATE 6/24/98, REPORT DATE 08/21/1998.

Additional Relevant Documents

1.) License amendment request dated May 23, 2012, seeking to increase the EDG minimum voltage from 4,031 volts to 4,070 volts. This license amendment request is posted online in ADAMS under ML12144A383.

2.) NRC email dated June 21, 2012, to FENOC, indicating that the LAR could not be accepted for review until some additional information was provided. That email is in ADAMS under ML14324A823.

3.) A FENOC letter dated July 16, 2012, to NRC, withdrawing the LAR. This letter is in ADAMS under ML12199A056. The letter indicated FENOC did not want to provide the additional information requested by NRC.

4.) July 30, 2012 letter from NRC to FENOC, acknowledging that the LAR had been withdrawn. This letter is in ADAMS at ML12200A387.

In an April 10, 2015 NRC "Component Design Bases Inspection Report" at Davis-Besse, NRC listed a "finding" re: "Vulnerability of Emergency Diesel Generator Crosstie to a Non-Essential Bus" (Page 10 to 12, or 13 to 15 on PDF counter)

Lochbaum at UCS: "Dark and Dangerous: Station Blackout"

David Lochbaum, director of the Nuclear Safety Program at Union of Concerned Scientists, has written a blog post entitled "Dark and Dangerous: Station Blackout."

It is part of the "Disaster by Design/Safety by Intent" series of blogs, posted at "All Things Nuclear" on the UCS website.

The blog post complements another Lochbaum wrote on March 17, 2011 -- six days (three meltdowns, and four explosions) into the the Fukushima Daiichi nuclear catastrophe, about which he co-authored a book, Fukushima: The Story of a Nuclear Disaster (New Press, 2014). That one was entitled "Nuclear 'Station Blackout,'" and explained the significantly increased risks of a core meltdown, in the event of atomic reactors experiencing not only loss of off-site power (LOOP), but also emergency diesel generator (EDG) failure, as happened at Fukushima Daiichi due to the earthquake and tsunami. Fukushima Daiichi's operating reactors had eight hours of DC battery backup, which nonetheless proved incapable of preventing three meltdowns over the course of the next several days.

By way of comparison, prior to the Fukushima catastrophe, only a small fraction of U.S. reactors had eight hours of backup batteries; most only had four hours worth.

Lochbaum's insights on the significantly increased risk of core meltdown and catastrophic radioactivity release, due to station blackout, sheds important light on U.S. reactors -- such as Davis-Besse in OH, where EDGs likely would not function properly in an emergency.

In fact, in another blog post by Lochbaum dated Oct. 20, 2015, also about loss of power at atomic reactors vitally needed to run safety and cooling systems, he documents a 2001 incident at Davis-Besse negatively impacting DC batteries connected to safety significant systems.

NRC rubber-stamps Entergy Palisades' operation till 2031, despite increasing risks of U.S.'s worst age-degraded reactor pressure vessel

A diagram describing pressurized thermal shock in a nuclear reactor. Credit: Japan Atomic Energy Agency. Japan's worst embrittled RPV, at Genkai 1, has been permanently closed in the aftermath of Fukushima.Beyond Nuclear and environmental allies responded to NRC staff's approvals (see below) with a press release (see the Word version for live links to relevant documents).

The Kalamazoo Gazette/MLive reported on this story, quoting the environmental coalition's attorney, Terry Lodge of Toledo:

"Once again, the NRC commissioners, and now staff, demonstrate that there is no way to thread the needle; the public remains excluded," said Terry Lodge, a Toledo attorney and legal counsel for the environmental coalition. "This is likely the public's last opportunity ever to question the absurdly embrittled and dangerous pressure vessel at Palisades. We can only hope the NRC's incurious facade and implacable public-be-damned attitude does not give rise to a spectacular radioactive catastrophe."

And the St. Joe-Benton Harbor Herald-Palladium reported:

Reaction from the anti-nuclear activist camp has been critical. Groups such as Beyond Nuclear have been pushing the NRC to force Palisades to shut down over safety concerns.

Kevin Kamps of Beyond Nuclear says the NRC keeps diluting the safety regulations for Palisades to keep allowing it to operate.

"They keep weakening the rules," Kamps said. "The NRC is a rogue agency and Entergy is a rogue corporation. The NRC has abandoned its conservative models. Palisades can't meet the old regulations, so magically there's a new regulation they can meet. They are shaving the safety margins. They're going right up to the cliff edge of risk."

Anti-nuclear organizations have been critical of the NRC for allowing Entergy to use data from metal samples from other nuclear plants' reactor vessels in its Palisades analysis.

WHTC reported:

The Nuclear Regulatory Commission’s decision to issue two license amendments involving the Palisades plant near Covert is coming under fire from anti-nuclear activist groups who continue to demand the closure of the 44-year-old facility. The NRC says that plant’s reactor vessel should remain safe for operation through 2031, when the Palisades’ license expires, and that staffers at the facility “successfully demonstrated the safety of the pressure vessel under current operating conditions.” Beyond Nuclear officials dispute these findings, claim that the NRC’s decision is based on greed, and vow to continue their high-visibility fight to close this plant.

WKZO reported:

A four-group coalition disputes these findings and claim that the NRC's decision is based solely on greed. U.S. House Energy and Commerce Committee Chairman Fred Upton of St. Joseph disagrees, however.

"There's no political arm-twisting," Upton said. "It's the science that determines the outcome."

Kevin Kamps of Beyond Nuclear accuses Upton of collusion with the NRC and Palisades' operator Entergy in a way that is "similar to the root cause of the Fukushima nuclear catastrophe in Japan."

The Detroit News also covered this story, reporting:

Longtime Palisades critic Kevin Kamps of the group Beyond Nuclear argues federal officials are putting the public at greater risk of an accident.

“NRC has custom-tailored weakened regulations to accommodate the severely age-degraded Palisades atomic reactor and to allow Entergy to run it into the ground until 2031,” Kamps said in a statement. “The collusion ... to keep Palisades operating is frighteningly similar to the root cause of the Fukushima Daiichi nuclear catastrophe in Japan. ...”

Beyond Nuclear is one of several groups involved in the Shutdown Before Meltdown campaign aimed at ending Palisades’ run as an active reactor.

NRC's approvals are but the latest instance of the agency ignoring warnings by environmental watchdogs and concerned local residents. For example, from 2012 to 2014, the coalition brought warnings from Japan to the attention of two NRC chairmen and another NRC Commissioner (Dr. Greg Jaczko, Dr. Allison Macfarlane, and William Magwood IV), at face to face meetings near Palisades after the officials had toured the problem-plagued reactor. The coalition shared articles, published by Hiromitsu Ino in the Citizens Nuclear Information Center-Tokyo newsletter (#148 and #149) in 2012, showing that Japanese nuclear power industry and nuclear regulatory agency models, regarding RPV embrittlement, were significantly non-conservative, as revealed when actual physical tests were finally performed at Genkai Unit 1. (See Figure 1 in newsletter #148, and Figue 2 in #149; also see illustration, above left).

The following email, sent by NRC Region 3 in Lisle, IL to news media, but not to concerned local residents or environmental groups, which have been officially intervening on reactor pressure vessel risks at Palisades for over a decade, was how Beyond Nuclear learned of NRC's approvals, when a reporter shared it:

"From: "Mitlyng, Viktoria" <Viktoria.Mitlyng@nrc.gov>

Date: November 23, 2015 3:38:50 PM GMT-05:00 

Subject: NRC approves two Palisades license amendments

NOTE TO MEDIA: NRC APPROVES TWO LICENSE AMENDMENT REQUESTS RELATE TO REACTOR VESSEL SAFETY

The NRC completed the review of and issued two license amendments which pertain to reactor vessel embrittlement under certain conditions for Palisades. The NRC granted these license amendment requests because they were found to maintain public health and safety The Pressurized Thermal Shock (PTS) amendment addresses the material behavior during a postulated accident event (PTS) and the Appendix G amendment addresses material behavior during normal operations.  While both are affected by embrittlement, they require examination and assessment of different data points.

PTS LAR

After 16 months and over 700 hours of independent review and verification, the NRC concluded that the probability of vessel fracture that could result from a PTS event at Palisades is so exceedingly low that it isn’t likely to present a danger to public health and safety.

The NRC granted Entergy permission to use an updated rule to assess the reactor vessel’s ability to withstand a certain type of accident. The original PTS Rule was published in 1985 while the Alternate PTS Rule was published in 2010. In the 25 years between the publishing of the two PTS rules, we acquired more data and a better understanding of embrittlement, as well as greater accuracy in computer modeling capabilities. Thus we are able to capture the details of a PTS event more accurately than was possible when the original PTS rule was adopted.

Both rules hold plants to the highest safety standards.

APPENDIX G LAR

After two years and over 800 hours of independent review, the NRC concluded that Palisades successfully demonstrated through fracture mechanics analysis the continued safety of the pressure vessel under current operating conditions.

Appendix G deals with NRC’s requirements for fracture toughness of the reactor vessel or the material’s resistance to fracture during normal operation.  The Appendix G regulations require that the reactor vessel maintain a minimum fracture toughness of 50 ft-lbs when measured by the Charpy test. The Charpy test is performed in a laboratory and measures metal fracture toughness.   If the tests shows that minimum fracture toughness will fall below the established value (50 ft-lbs), NRC regulations require the plant to perform fracture mechanics analysis to demonstrate that the reactor vessel will not develop significant flaws under normal conditions. This analysis is often referred to as an equivalent margins analysis (EMA). The NRC has reviewed this type of amendment and analysis for numerous reactors.  

The NRC staff has completed its review of the licensee’s EMA and determined that at the lower fracture toughness levels that have been predicted for the Palisades vessel, the likelihood of reactor vessel fracture remains extremely low under the conditions for which the reactor was designed through the end of the current license (March 24, 2031).

REACTOR CAPSULES

The NRC staff notes that the Palisades capsules contain test specimens from the reactor vessel, but not from the specific plates and welds which are the subject of the Palisades Appendix G submittal.  Therefore, when the next capsule withdrawal and test occurs, the capsules will provide embrittlement information for only certain reactor pressure vessel materials. They will not provide any additional information on the materials discussed in Entergy’s Appendix G submittal."

Attached to the email were the NRC's "Appendix G Approval" and "PTS Amendment Approval" documents.

Davis-Besse nuke license renewal challenged due to cracking issue

Matthew Bandyk at SNL has quoted Beyond Nuclear:

"The prospect of 22 more years of radioactive Russian roulette on the Lake Erie shore, with a cracked concrete containment, and paid for by a multibillion-dollar ratepayer bailout, is outrageous, and must be prevented," the group said in a Nov. 7 report following the hearings...

Beyond Nuclear pointed to testimony from a Sept. 23 NRC meeting, in which an NRC engineer said it was "possible," although "unlikely," that an earthquake could cause a cracked piece of concrete to "spall off." Concrete that fell off the shield building could damage the plant's auxiliary building, which is used to house safety features like emergency cooling systems...

In most cases, the NRC staff can complete a license renewal review in about two years, according to NRC spokesman Scott Burnell. But FirstEnergy submitted its application for Davis-Besse in 2010. It is typical for renewals that involve proceedings before the Atomic Safety and Licensing Board to take longer, he said. Beyond Nuclear and several other groups, such as the Ohio Green Party, filed multiple contentions about the cracking to try to block Davis-Besse's license renewal, but the board refused to grant them a hearing.

FirstEnergy President and CEO Charles Jones Jr. recently said that in early 2016 it expects a settlement with the Public Utilities Commission of Ohio that will resolve the proposed power purchase agreement. Beyond Nuclear called upon Ohio residents to oppose the agreement, saying it amounts to "$3 billion in ratepayer subsidies, to prop up [FirstEnergy's] age-degraded and uncompetitive Davis-Besse reactor" and that it would cost more than $3 billion to replace Davis-Besse's reactor containment if the cracks worsened.

NRC dismisses Beyond Nuclear et al. interventions against Entergy Palisades RPV risks; environmental coalition vows to fight on

NRC file photo of Entergy's Palisades atomic reactor on the Lake Michigan shore in Covert, MIAn environmental coalition (Beyond Nuclear, Don't Waste MI, MI Safe Energy Future, and Nuclear Energy Information Service of IL, represented by Toledo attorney Terry Lodge, and served by expert witness Arnie Gundersen of Fairewinds Associates) has been officially intervening against yet further regulatory rollbacks at Entergy's Palisades atomic reactor since Dec. 1, 2014. Entergy Nuclear has applied to the U.S. Nuclear Regulatory Commission (NRC) for weakened safety regulations, to accommodate Palisades' continued operations, despite having the single worst embrittled reactor pressure vessel (RPV) in the U.S., and other forms of severe, and worsening, RPV age-related degradation. Palisades has operated for nearly 45 years. It is located on the Lake Michigan shoreline in Covert, MI (see photo, left).

The NRC Commissioners have been considering dueling petitions filed by the environmental coalition and Entergy. On June 2, 2015, the coalition appealed an Atomic Safety and Licensing Board Panel (ASLBP) rejection of its contention regarding RPV embrittlement, and risks of pressurized thermal shock brittle fracture due to suddenly decreasing temperatures. On July 13, 2015, Entergy appealed the same ASLBP's granting of a hearing to the environmental intervenors on the technical merits of their contention, regarding other forms of RPV age-related degradation, and risks of ductile tearing failure even at hotter normal operating temperatures. Either form of failure of the RPV would lead to Loss-of-Coolant-Accident, and reactor core meltdown, and likely containment breach and release of catastrophic amounts of hazardous radioactivity.

Today, the NRC Commissioners ruled Entergy's way in both overlapping proceedings, denying the environmental coalition's appeal, while ruling in favor of Entergy's appeal.

The coalition, working in alliance with groups like the Sierra Club Nuclear-Free Michigan Committee, has vowed to fight on, to demand Palisades' shutdown, before it melts down. It has issued a press release. (See the word version for functional links to relevant documents.) Matthew Bandyk at SNL has reported on this story.

The NRC Commissioners' overruling of its own ASLBP grant of a hearing comes despite the environmental coalition’s efforts having garnered the support of the mayors of Grand Rapids and Kalamazoo. Grand Rapids (with a population of 200,000) and Kalamazoo (with 75,000 residents) are the two largest cities in southwest Michigan, both well within the 50-mile zone downwind of Palisades. On July 30, 2015, Grand Rapids Mayor George Heartwell wrote the NRC, urging that long overdue physical safety testing of Palisades’ RPV be conducted, and that the environmental groups’ intervention be allowed to proceed to a hearing. Echoing those calls, on November 6, 2015, Kalamazoo Mayor Bobby J. Hopewell went even further, urging “From the information presented…the requested regulatory relief should be denied to ENTERGY.”

Likewise, on August 4, 2015, the nearest residents to the Palisades atomic reactor, the Palisades Park Country Club, also demanded the long overdue physical safety testing, and called for the hearings to proceed.

On August 7, 2015, so too did the Sierra Club, “the nation's largest and most influential grassroots environmental organization -- with more than two million members and supporters.” The Sierra Club’s attorney, Wally Taylor, filed a Friend of the Court brief in support of the environmental coalition’s efforts, on behalf of its Nuclear-Free Michigan Committee, chaired by Mark Muhich of Jackson, MI.